Appendix K, Comment Period
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Review of Emergency Preparedness of Areas Adjacent to Indian Point and Millstone Appendix K: Results of the Comment Period Executive Summary On January 10, 2003 James Lee Witt Associates (JLWA) completed a draft comprehensive and independent review of emergency preparedness for the area around the Indian Point Energy Center (Indian Point) and for that portion of New York in proximity to the Millstone plant in Connecticut. Because of the importance of the subject to the citizens and stakeholders in the area, and because we thought consideration of comments would improve the report, JLWA thought it appropriate that the public have an opportunity to provide comments on any aspect of it. The State concurred in this assessment and approach. Although JLWA received 72 submissions that contained hundreds of individual comments, few changes in the draft were required due to factual errors. The comments that addressed major, substantive issues were not sufficiently compelling that the draft’s major findings, conclusions and recommendations needed to be changed in the final report. Changes to the final report are explained in this appendix. Based on the submissions and comments received, as well as the public debate that followed the release of the draft report, JLWA finds it both necessary and appropriate to emphasize or clarify some issues we may not have accentuated in the draft: • Closing the plants would not remove the need for improvements ...

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Review of Emergency Preparedness of Areas Adjacent to Indian Point and Millstone
Appendix K: Results of the Comment Period

Executive Summary

On January 10, 2003 James Lee Witt Associates (JLWA) completed a draft comprehensive and
independent review of emergency preparedness for the area around the Indian Point Energy
Center (Indian Point) and for that portion of New York in proximity to the Millstone plant in
Connecticut. Because of the importance of the subject to the citizens and stakeholders in the
area, and because we thought consideration of comments would improve the report, JLWA
thought it appropriate that the public have an opportunity to provide comments on any aspect of
it. The State concurred in this assessment and approach.

Although JLWA received 72 submissions that contained hundreds of individual comments, few
changes in the draft were required due to factual errors. The comments that addressed major,
substantive issues were not sufficiently compelling that the draft’s major findings, conclusions
and recommendations needed to be changed in the final report. Changes to the final report are
explained in this appendix.

Based on the submissions and comments received, as well as the public debate that followed the
release of the draft report, JLWA finds it both necessary and appropriate to emphasize or clarify
some issues we may not have accentuated in the draft:

• Closing the plants would not remove the need for improvements in emergency
preparedness.
• The existing plans should be followed during an emergency. Our intent was not to
discredit the plans, but to improve them.
• Almost all of the inadequacies that we pointed out would exist without a possible terrorist
threat, and should be addressed.
• The plants and those with responsibility to protect the population in the adjacent
communities meet current NRC and FEMA regulatory requirements. FEMA and NRC
regulations are in need of review, however.
• There are unique aspects of a terrorist-caused incident that should be considered in
planning and exercising.
• We make no assertions that a terrorist attack would cause a faster or larger release.
• Some have attempted to discredit us and this report on the basis that it is not scientific.
We are confident that our emergency management credentials qualify us to present our
findings, conclusions and recommendations.

The above points and issues are thoroughly addressed in what follows. In addition, many other
issues with which the public is concerned are discussed, such as shadow evacuation, first
responder and parental behavior, the potential for a release, the adequacy of the ten-mile EPZ,
the findings of disaster research, and exercising for rapid and large releases.

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Background

Prior to the release of the January 10, 2003 draft review JLWA sought and was granted a time
extension from the State to incorporate a public comment period into the report. Because of the
importance of the subject to the citizens and stakeholders in the area, and because we thought
consideration of comments would improve the report, we thought it appropriate that the public
have an opportunity to provide comments on any aspect of it. The State concurred in this
assessment and approach.

The draft review was made available for public comment on the JLWA website Friday, January
10, 2003. The public comment period closed Friday, February 7, 2003.

We received submissions from 72 sources. They came from the following sources: energy
producers and affiliates, local and county government, activist groups, other groups, and
individuals. We thank those who took the time and effort to constructively comment.

The contents of submissions and comments range from praise to censure, from general to
specific, and from questioning our motivations to suggesting additional improvements we should
recommend. This range of reaction was expected. The remainder of this appendix will tell how
we treated the comments received, and the results of the process, including the changes now
found in the text of the report.

Process

We assigned codes to the issues raised in the submissions so that we could provide an indication
in this final report of the frequency of specific issues. Issues of a technical nature requiring the
input of our technical subcontractors, Innovative Emergency Management Inc., were forwarded
for their review.

After the initial review of the responses, issues were grouped and summarized to encompass
variations in the statement of the issue without over generalizing and, thus blending separate
issues. The issues were then analyzed and divided into the categories found below:
A. Issues with which we agree, but did not emphasize or clarify sufficiently in the draft.
B. Comments with which we agree, and that require modification of the draft.
C. Comments with which we disagree and will not modify the draft.
D. Comments with which we may or may not agree, but that do not require a change in the
draft.
E. Comments that may be relevant to issues in or tangential to the draft, but that fall outside
of the scope of our work.

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Comments, Issues, and Analysis

A. Issues with which we agree, but did not emphasize or clarify sufficiently in the
draft.

We are aware of the public and political reactions that have resulted from the issuance of the
draft report. The issuance of the draft for public comment is evidence of our concern that our
report not be used in a way that would mislead or misinform the public. We are also concerned
about possible misrepresentation of the report. As a consequence we feel it both necessary and
appropriate to emphasize some issues we may not have accentuated or clarified sufficiently in
the draft.

1. Closing Indian Point would not remove the need for improvements in emergency
preparedness. We believe most people recognize that closing the plant would not remove
the source of radiation and that special provisions for the protection of people, common
to all nuclear plants, would need to remain in place. We are concerned that decision
makers and the general public not lose sight of the need to make improvements. This
will require federal, state, local, business and citizen support, including financial support,
as those responsible struggle with some very difficult issues.

It is possible that visible improvements would be of value in raising public confidence
about the degree of protection available, and that that enhanced public confidence may
result in behaviors that improve the effectiveness of a response.

2. The existing plans should be followed during an emergency. Our intent was not to
discredit the plans, but to improve them. Our experience leads us to believe public safety
is enhanced by adherence to the recommendations of public authorities charged with the
protection of public safety. Those authorities should use the plans they have, adjusting
them according to circumstances and their best judgment. A plan should be viewed as a
living document that is constantly evolving and being improved.

3. The media and others are focusing on the terrorist threat to the plant itself. We have not
focused on any possible threats to the plant. The draft report identified a variety of
significant issues that need to be addressed, regardless of a terrorist threat. We are
concerned that the issues that exist independent of a possible terrorist threat are not
getting the attention they deserve.

4. Both Millstone and Indian Point meet current NRC and FEMA standards. The NRC has
stated as recently as November 18, 2002, that FEMA’s preliminary assessment of the
capabilities of, and compliance by, the State and its jurisdictions, based on the September
24, 2002 exercise, indicates the off-site emergency plans are adequate to protect public
health and safety. Although we may come to different conclusions regarding adequacy
apart from the standards, and believe NRC and FEMA requirements need revision, we
recognize that those requirements are the product of many years of serious thought and
strenuous effort dedicated to the public well-being.

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Related to this issue is the high standard to which we hold ourselves. In other words, is
there anything short of perfection that will satisfy us? We neither expect nor require
perfection in a plan. We note in the draft that disaster experience shows how people can
rise to an occasion, how responses can be effective in spite of defective plans, and how
plans for one event can be used for other events. Nevertheless, we have not seen a plan
that had no room for improvement, and our task was, in part, to recommend
improvements whether or not the plans met current requirements. In so doing we needed
some standard to measure the effectiveness of protective measures. We used the EPA
Protective Action Guideline as the one most applicable, recognized and defensible. The
result of these considerations and our review was a set of recommendations that do
involve a high standard of protection. We do not consider that standard impossible or
unreasonable, but readily recognize that some in our profession may disagree.

5. There are some unique aspects of terrorism that off-site planning and exercising should
address. There may be some planning and response considerations that are not
addressed in “tried and true” planning and exercising. For example, there may be impacts
on the thinking, emotions and reactions of the population and responders when the report
of an accident says “radiological release” and “terrorism” in the same sentence. Although
we do not know for certain what those impacts are, they should not be ignored using the
argument that the off-site response to a terrorist-induced event would be the same as the
response to any other event.

Another example is an incident that involves multiple, nearly simultaneous obstruction of
evacuation routes in addition to those that would occur in a “normal” evacuation.
Because these obstructions can be assumed to be deliberately designed to cause
disruption, they may also be more difficult to address than normal traffic problems.

Another example would be actions that target responders.

An additional question that needs to be explored is whether there would be higher levels
of convergence (arrival of people into the area) in a terrorist event than has already been
documented for radiological events such as Three Mile Island. We expect, too, that
spontaneous evacuation may be more of a problem than it would be in a non-terrorist
event.

The bombing of the Murrah Federal Building in Oklahoma City in 1995 demonstrated
how the presence of a crime scene significantly changes the communications and
coordination aspects of a disaster response. Those who are responding to a terrorist
assault are no longer available for normal event law enforcement activities, such as the
safe evacuation of the affected populace.

In the response to a terrorist event at Indian Point or Millstone, it may well be that news
media, law enforcement and/or others reduce the degree of control over the content and
timing of information that the plant authorities would otherwise have. Agencies, such as
the FBI, will likely insist on involvement in both on-site and off-site activities in ways
not contemplated in existing plans and exercises.
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6. We attempted to take no position on whether a terrorist act could cause a faster or larger
release. On page 240 we stated, “When considered together, however, it is our conclusion
that the current radiological response system and capabilities are not adequate to
overcome their combined weight and protect the people from an unacceptable dose of
radiation in the event of a release from Indian Point, especially if the release is faster or
larger than the typical REP exercise scenario (often called “design-basis release”)
(emphasis added). On page viii of the Executive Summary, we shortened the highlighted
phrase to “… especially if the release is faster or larger than the design-basis release.”
We considered these to be equivalent statements. Nevertheless the phrase in the
Executive Summary caused confusion, and charges that we assert a terrorist attack can
result in a faster and/or larger release, an issue upon which we intended to take no
position. Consequently, we have changed the wording in the Executive Summary.

7. We were asked to provide our observations and recommendations as experts in the field
of Emergency Management. We did not attempt to adjudicate disputes among scientists,
such as the probabilities of a release. We disclaimed such intentions on page 19 of the
draft. Nevertheless, some have attempted to discredit us and the draft on the basis that it
is not scientific.

We are confident that our emergency management credentials qualify us to present our
findings, conclusions and recommendations. We would suggest that nuclear engineers
and others who take us to task for inadequate scientific rigor in what we say about
emergency management might first consider their own qualifications in our field. They
are entitled to disagree, as might some of our colleagues in emergency management, but
they should not scorn our findings, conclusions and recommendations on the grounds that
they lack scientific demonstrability.

8. Emergency management is not the only issue involved in the debate about nuclear power
plants. We made it clear in the draft that alternate sources of energy and economic
considerations are important, even though we were not asked to address them. Most
public enterprises involve some degree of risk. Although we have questioned the degree
to which the public is protected in the event of a release, we have not addressed the
degree of risk people are willing to accept in exchange for benefits they receive, which is
another legitimate aspect of the debate.


B. Comments with which we agree, and that require modification of the draft.
(Note: Comments are summarized. Each comment includes a number in parentheses,
representing the number of correspondents that raised a recognizable version of that issue.)

1. Comment (1): Given the reaction to the draft, the final report should emphasize some of
the qualifications JLWA made, or should have made, regarding its scope and findings, so
as to minimize misuse of the report and promote the public’s understanding of the issues
and JLWA’s position.

Response: We agree, and have emphasized issues and qualifications in A above.
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2. Comment (2): The report should provide some of the typical probabilities of a severe
accident, as determined by the referenced “probabilistic risk studies.” The probabilities
should also be compared to the probability of other events that the reading public may be
familiar with, in order to provide an accurate picture of the risk involved.

Response: We agree the information has value and have included it in Section 3.1 of the
text.

3. Comment (2): Spontaneous evacuation is not indisputable (page ix). Most people are
somewhat reluctant to abandon their homes, even under an obvious threat such as severe
weather or spreading fire. Many educated people do not have an irrational fear of
radiation and the EPA threshold of one REM is not a significant dose. There would not
be panic, unless there were a full-scale terrorist assault on the plant. Also, spontaneous
evacuation typically facilitates an official evacuation because a portion of the population
has loaded onto the evacuation network before the peak loading.

Response: We agree spontaneous evacuation is not “indisputable”, as is evidenced by
these comments, and have dropped that word on page ix of the draft accordingly. We did
not use the word “panic” anywhere in the draft report, but we do agree a terrorist attack
would aggravate whatever spontaneous and shadow evacuation might otherwise be the
by-product of an accident.

We have not tried to determine what most people would do. We agree that some will
stay in their homes in spite of the most clear threat, and warnings from public officials.
We stated that a percentage sufficiently large to have public safety implications will
probably evacuate unnecessarily, and that the plans should accommodate this likelihood.
The draft is not incorrect in this regard.

It is possible that spontaneous evacuation may facilitate official evacuation, as asserted in
one of the comments. If there is a long time of uncertainty during a slow evolving crisis,
spontaneous evacuation may have the potential to reduce peak loads later. Such may be
the case for slow-moving events such as hurricanes, or a slowly building nuclear plant
emergency. But the assumption that spontaneous evacuation is beneficial cannot be
supported under a variety of other conditions. If there is significant evacuation from the
non-recommended areas, the recommended population may not be able to evacuate
rapidly from the region. This is especially true in regions where the available road
capacity is not in balance with existing, ambient traffic. It is especially the case for acute
emergencies where there is little forewarning, and preemptive evacuation must be
completed swiftly to reduce exposures.

The problem is compounded if people are biased toward using specific destinations or
1routes. In a survey of Shoreham area residents, researchers (Ziegler et al. ) found that 60-
70% of the residents on the east side of the Shoreham plant indicated that they preferred

1 Ziegler et al., 1981. “Evacuation from a Nuclear Technological Disaster” in Geographical Review, 71:1-16.

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destinations in the next county, New York City or even beyond. Other researchers have
noted that the movement of some evacuation traffic may be directional – many people
utilizing a limited set of evacuation routes. This type of behavior is also recognized in
the transportation engineering discipline and given the term “user equilibrium.” Such
behavior may create localized congested areas that could result in much longer
evacuation times for some evacuees. Depending on the location of the hazard, these
longer evacuation times may result in greater exposure.

What happens typically in disasters is not necessarily applicable to the Indian Point area
in a radiological event, especially considering its relatively dense population, high level
of public awareness, and problematic road network. Our concerns remain valid;
unnecessary evacuation may adversely affect the timely evacuation of those who should
evacuate, and the plans and exercises should reflect this reality.

4. Comment (1): JLWA was not asked to look at the economic benefits of the plant, and
therefore should not have that type of information in the report. If that information is
provided, it should be balanced by the costs born by the public for the continued
operation of the plant.

Response: We agree with the logic of the criticism and have deleted the appropriate
paragraph from page 7 of the draft.

5. Comment (5): The draft fails to mention contributors and their qualifications. Such a
listing is standard practice in reports of this type.

Response: We agree contributors and their qualifications need to be identified. See the
Contributors List following Chapter 11 and preceding the Appendices.

6. Comment (1): The remarks on page 173 pointing out the relative values of interviews
versus actual drills in a government’s exercise program also apply to businesses and
others. JLWA recommendations should reflect this important finding.

Response: We agree, and have inserted language in Section 11.2.2.2.

7. Comment (1): The listing of parks within the EPZ on table D-14 is incomplete.
Municipal parks, recreation centers and summer camps need inclusion in County and
local planning.

Response: We agree. The table should be expanded. Because we would not be able to
obtain the information in time to insert it, we have added a footnote to alert planners of
the need to expand the list.

8. Comment (1): The final report should clearly recommend inclusion of the dangers of
radiation in the Planning for Emergency booklet.

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Response: It is true that our recommendation is only implied by our remarks on page 153
of the draft, and is not explicitly stated. It is stated more clearly in Section 7.2.1 of the
final report.

9. Comment (2): The draft report incorrectly attributes the location of the primary
meteorological tower for Indian Point.

Response: The comments are correct. The location of the primary meteorological tower is
incorrectly specified in the draft report as mounted on one of the Indian Point
containment structures. IEM meteorologists collected detailed information on the weather
instrumentation, data handling, archiving and maintenance in a conference call with
Entergy personnel prior to publication of the draft report. In the notes captured from this
telephone exchange, the location of the primary meteorological tower was recorded as
mounted on the containment building for the Unit 1 reactor. This is the non-operational
unit at Indian Point so the note was not questioned further in the pre-draft review. Based
on the comments, IEM conducted a follow-up verification visit to the Indian Point
Emergency Operations Facility in February 2003. During this visit, we confirmed the
actual location of the primary tower. It is located in the southern portion of Indian Point,
adjacent to the loop road immediately southwest of the Indian Point Training Center.

The first sentence of the second paragraph on page 31 of the draft report and the second
paragraph of page B-4 have been changed accordingly.

10. Comment (1): The reference to the use of several Personal Home Alert Devices (PHADS)
in use on home electric meters is incorrect. These devices are not used at Indian Point or
in the surrounding community.

Response: The comment is correct. Based in part on this comment, IEM conducted a
follow-up visit to the Indian Point Energy Center Emergency Operations Facility in
February 2003. During this visit IEM confirmed that the PHAD devices were not used to
support Indian Point alert and notification. IEM then sourced the comment in the draft. It
appears that tone alert radios (TARS, a total of 378 of these devices are used in the
community) used in one county were described as “personal home alert devices” to a plan
reviewer. Further research on the term led to the reference and specification for PHADS
and subsequently an incorrect attribution in the alert and notification section of the draft
report.

th th thWe have deleted the 4 , 5 and 6 sentences of the first paragraph of Section 5.3.1 on
page 106 of the draft report.

11. Comment (29): The assumption that the consequences of an event at Indian Point caused
by terrorist action are unique because they involve the potential for a quicker or larger
release, is not correct. The existing planning basis for US nuclear facilities encompasses
the times postulated for credible terrorist initiated releases, and there is not a credible
terrorist initiator that can cause a larger radiological release than already postulated for
plant upset conditions. Thus terrorism is already covered in the plans.
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Response: NUREG-0654, Table 2 provides planning-basis guidance regarding time
factors associated with releases. This information is provided below:

Time Factor Range of Times
Time from the initiating event to 0.5 hours to one day
start of atmospheric release
Time period over which 0.5 hours to several days
radioactive material may be
continuously released
Time at which major portion of 0.5 hours to 1 day after start of
release may occur release
Travel time for release to exposure 5 miles – 0.5 to 2 hours
point (time after release) 10 miles – 1 to 4 hours

The JLWA/IEM review team was provided with an executive summary of the study,
“Deterring Terrorism: Aircraft Crash Impact Analyses Demonstrate Nuclear Power
Plant’s Structural Strength,” prepared by the Electric Power Research Institute (EPRI) at
the request of the Nuclear Energy Institute (NEI). This report was finalized in December
2002, shortly before public release of our draft report. After release of the draft, we
received and reviewed their executive summary, which was the only part of the study
readily available to us in writing, and the general study conclusion that aircraft impact on
structures housing reactor fuel poses a low risk of resulting in a radiological release. We
also reviewed other information that challenged the conclusions of the aircraft crash
analysis.

The JLWA/IEM team was also provided with an executive summary of a draft study
requested through the NEI by the Nuclear Regulatory Commission (NRC) to assess the
consequences of a hypothetical terrorist ground attack on a commercial nuclear power
plant. The study, also completed by the EPRI, was completed as a draft and was also
dated December 2002. The executive summary was the only part of this study readily
available to us. Based on the fact that the study conclusions are still in draft and subject
to scientific peer review, we considered the executive summary conclusions with that
caveat.

JLWA received a number of comments either challenging or supporting the draft report
position that Indian Point REP planning, and more notably exercising, needed to address
faster times to release (the term fast breaking event was also used in the draft report).
Based on our review of past full scale exercise reports, we found that the scenarios did
not have a time to release less than 3.5 hours. In February 2003, IEM also reviewed
additional Indian Point plant drill scenarios and participation matrices. Although some
had times to release less than the full scale exercise times, they did not have the level of
participation of an FSE, and were “faster” in part to fit condensed schedules to allow play
to finish within the short time allowed for the drills. (See the separate response specific to
release durations, in this appendix below, for more details).

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From the initial review (and the February 2003 follow-on review) we concluded that the
low end of the time range specified in NUREG 0654 is not being sufficiently exercised.
Thus, we brought attention to the need for more planning and exercise attention on fast
breaking releases. In addition to developing scenarios for full participation exercises that
have shorter times to release, the participating organizations need to focus on measuring
how quickly the population is being affected compared to the speed with which they are
accomplishing protective actions. Simply running a faster scenario and stopping short of
that type of performance measurement is inadequate to effectively judge how well the
population was protected. Both activities are needed, and this was the basis for some of
the recommendations in the draft report.

We approached release size in a similar manner; as stated in the draft report, a wide range
of planning accidents should be considered. These accidents should have a large
variation in quantity of radiological material released and consequences to the population.
We did not see evidence of consideration of wide variations in releases in our initial
review or in our observation of the practice and full scale exercises. Historical exercise
reports do not contain detailed information on the size of the release (release quantity,
rate, mix of isotopes, etc.), so we were not able to look at this question historically.

There was an additional limitation on the amount of detailed plant-specific planning-basis
information, especially the types of accidents that were covered in the plant probabilistic
risk assessment (PRA) and associated updates. In the February follow-on effort we
attempted to explore the issue of the range of PRA accidents analyzed for Indian Point
and their connection to the exercise scenario development. We sought but did not receive
plant information specific to this purpose. Unless we can verify where the “band” of
exercise releases falls within the larger continuum of planning-basis accidents, we can
not assume that there is coverage at the “larger release” end of the scale.

Releases have been postulated by other stakeholders and technical reports that certainly
exceed the size observed in the 2002 FSE. Although some, including those aligned with
the nuclear power industry, dismiss the necessity to exercise larger releases because they
are low credibility and probability events, this is not sufficient reasoning to exclude these
scenarios from exercises. Such decisions require scientific consensus and participation of
the REP stakeholders responsible for protection of the public.

There were a number of comments that took positions, both pro and con, on the relative
likelihood of large accidental releases, fast-breaking events, and nuclear accidents in
general. There were a number who stated that nuclear accidents from terrorists or other
causes, with larger or faster release characteristics, were not credible or were already
subsumed in both planning and practice. We maintain that it is not our mandate to pass
final judgment on the validity of one side of the probability debate or the other. We leave
that to the scientific community to come to consensus on the issue. In the absence of an
industry independent consensus scientific position, we will continue to evaluate Indian
Point emergency preparedness on the basis that a large, rapid release of radiological
material to the atmosphere is possible, and that a possible cause may be terrorism. This
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